Greenwashing Crackdown: Why Vague Carbon Claims Could Land You in Trouble

The Greenwashing Crackdown Is Real

In 2023 and 2024, UK regulators dramatically stepped up enforcement against misleading environmental claims. The Competition and Markets Authority (CMA), the Advertising Standards Authority (ASA), and the Financial Conduct Authority (FCA) have all made greenwashing a priority. This has direct implications for how businesses present their carbon reduction plans and environmental commitments.

The message from regulators is clear: if you make environmental claims, they must be accurate, substantiated, and not misleading. Vague statements like “we are committed to sustainability” or “carbon neutral by 2030” without evidence to back them up are now actively scrutinised.

CMA Green Claims Code

The CMA published its Green Claims Code in September 2021, setting out six principles that environmental claims must meet:

• Truthful and accurate — claims must reflect the real environmental impact of a product or service
• Clear and unambiguous — the meaning must be obvious to the average consumer
• Not omitting important information — you cannot cherry-pick positive aspects while hiding negatives
• Only making fair and meaningful comparisons — comparing like with like, using consistent methodologies
• Substantiated — you must have robust evidence to support your claims before making them
• Not containing misleading imagery or language — no green leaves and blue skies if your product is not genuinely sustainable

The CMA has conducted sector reviews in fashion, fast-moving consumer goods, and financial services. Businesses found to be making unsubstantiated claims have been required to amend or withdraw them. The CMA can take enforcement action under consumer protection law, including financial penalties.

What This Means for Your CRP

A carbon reduction plan is not immune from greenwashing scrutiny. If your plan makes claims that are not substantiated by the data, you are exposed. Common problems include:

• Claiming “carbon neutral” when you are relying entirely on offsets rather than actual reductions
• Setting Net Zero targets without a credible pathway showing how you will get there
• Reporting only Scope 1 and 2 while claiming to have measured your “full” carbon footprint
• Using outdated emission factors to make your footprint look smaller than it is
• Making reduction claims based on grid decarbonisation rather than your own actions

The ASA and Environmental Advertising

The Advertising Standards Authority has upheld multiple complaints against businesses making unsubstantiated carbon claims in marketing materials. Recent rulings have found against companies that:

• Claimed to be “carbon neutral” based solely on offset purchases
• Used the phrase “net zero” without explaining what it meant in their context
• Made environmental claims in advertising that were not supported by the company’s actual CRP

If your marketing team is making claims about your environmental performance, those claims need to be directly traceable to credible data in your carbon reduction plan.

How to Get It Right

The safest approach is also the most effective: measure properly, report honestly, and let the data speak. A credible carbon reduction plan should:

• Use recognised methodology (GHG Protocol, DEFRA emission factors)
• Cover all three scopes transparently
• Set targets based on science (SBTi methodology)
• List specific, realistic reduction measures
• Be updated annually to reflect progress

Every Carbonhogs plan is built on DEFRA 2024 emission factors and the GHG Protocol Corporate Standard. No vague claims, no inflated promises — just accurate data, credible targets, and specific actions. That is the kind of plan that stands up to scrutiny from regulators, evaluators, and clients alike.